STATE OF IOWA DEPARTMENT OF COMMERCE BEFORE THE IOWA UTILITIES BOARD : IN RE: : DOCKET NO. NOI-2011-0002 : HIGH VOLTAGE TRANSMISSION : COMMENTS OF CLEAN LINE PROJECTS : ENERGY PARTNERS LLC : : COMES NOW Rock Island Clean Line LLC (“Clean Line”) and, by way of response to the Iowa Utilities Board (“Board”) “Order Opening Inquiry on High-Voltage Transmission Projects and Soliciting Comments” (the “NOI”), submits its comments. The Board’s questions will be set forth and the responses of Clean Line will follow each in order. This Response includes photographs, tables and graphs that serve to illustrate points made in the response. 1. Describe the proposed project, including beginning terminus and end terminus (at least by county, with a more detailed description if possible), MW size, DC-Classic or DC-VSC or AC configuration, location of interconnects with existing facilities and other major facilities such as converter stations or substations, and proposed construction commencement and in-service dates. Iowa has some of the best wind resources in the nation, but the transmission infrastructure does not exist to connect those resources with communities and cities that have a strong demand for renewable energy. Because the vast majority of electric transmission development occurred before the start of the modern wind energy era, the northwestern region of the state, with its superior wind resources, contains enormous, undeveloped wind potential. In fact, several counties with world- class wind resources lack any operating wind farms. Clean Line is developing the Rock Island Clean Line, an approximately 500-mile, overhead High Voltage Direct Current (“HVDC”) transmission line, to connect the renewable resources in northwest Iowa and the surrounding region with communities in Illinois and in other states to the east (the “Project”). The Project will make possible 3,500 megawatts (“MW”) of new wind energy projects that could not otherwise be built due to the limitations of the existing electric transmission grid. The name of the Project originates from the Rock Island Railroad, which stretches across Iowa and Illinois. Just as the Rock Island Railroad allowed farmers to move their goods to market, the Rock Island Clean Line will deliver clean energy to the communities that need it, representing the new farm to market road for the 21st century. The Project will consist of one bi-pole ±600 kilovolt (“kV”) HVDC Classic transmission line capable of delivering up to 3,500 MW of power and will make possible approximately $7 billion in renewable projects at the western end of the line—creating thousands of jobs. The Project will deliver enough clean energy to power around 1.4 million homes, reduce power prices for consumers, contribute to energy security, increase state and local tax revenues, and reduce both pollution and water consumption. A. Location The planned location for the western converter station is O’Brien County, Iowa. The eastern converter station will be located in Grundy County, Illinois. As shown in Figure 1, the Rock Island Clean Line will draw from some the best wind resources in the country and deliver into a network of extra high voltage transmission lines that serve Illinois and much of the Midwest and Mid- Atlantic. -2- Figure 1: Rock Island Clean Line Project The region from which the Rock Island Clean Line will source its energy contains the best average wind speeds along the eastern edge of what many call the “Wind Belt.” Large areas of the resource area (circled in Figure 2) have average 80-meter wind speeds of 8 meters per second (about 18 miles per hour) or greater. Working with the meteorology firm AWS Truepower (“AWS”), the National Renewable Energy Lab (“NREL”) published the map of average wind speeds at 80 meters in Figure 2 below. Source: US Department of Energy, National Renewable Energy Laboratory Figure 2: USA Wind Speeds at 80 M Hub Height -3- The potential power generated by a wind turbine is proportional to the cube of wind speed (among other factors such as air density and swept area of the blades); as a result, relatively small differences in average wind speed can result in dramatic disparities in wind power potential. NREL and AWS have published a ranking of wind capacity potential at or above a 40% gross capacity factor by state, referenced in Table 1. As a testament to their superior wind resources, three of the four states from which the Rock Island Clean Line is likely to draw wind power—Iowa, Nebraska and South Dakota — are ranked in the top ten in wind potential. Each state has significantly more potential than the capacity of the Project. This suggests that it is feasible to fill the Rock Island Clean Line with an abundance of high capacity factor wind energy. Table 1: Wind Capacity Potential by State Windy Land Area >= 40% Gross Capacity Factor at 80 m Wind Energy Potential Ranking (by Total Excluded Available Available Installed Capacity Annual Generation Capacity Potential) State (km2 ) (km2) (km2) % of State (MW) (GWh) 1 Texas 180,822 15,426 165,397 24% 826,983 3,240,930 2 Nebraska 165,445 10,012 155,433 78% 777,165 3,084,090 3 South Dakota 163,281 10,004 153,277 77% 766,383 3,039,460 4 Kansas 163,170 11,105 152,065 71% 760,324 3,024,280 5 North Dakota 160,497 21,932 138,564 76% 692,821 2,728,620 6 Montana 98,309 18,737 79,571 21% 397,857 1,529,560 7 Iowa 72,119 8,400 63,719 44% 318,595 1,232,860 8 Wyoming 70,268 17,787 52,482 21% 262,410 1,043,890 9 Oklahoma 55,593 6,038 49,555 27% 247,773 952,687 10 New Mexico 39,574 2,425 37,149 12% 185,745 712,877 Source: US Department of Energy, National Renewable Energy Laboratory In fact, as shown in Figure 3, AWS and NREL slate Iowa’s high capacity wind potential at 28 times Iowa’s current annual energy consumption, again supporting significant wind export opportunities for the state. -4- Source: NREL, EIA. High capacity factor defined as >40% CF at 80 m hub height. Figure 3: Iowa high capacity wind potential vs. electric demand Developers are advancing projects totaling tens of thousands of MW in the resource area. Over 51,000 MW of active wind projects are in the MISO Interconnection Queue, of which over 31,000 MW are located in Iowa, Minnesota, Nebraska or South Dakota. In addition to those projects in the interconnection queue, there are many wind projects with meteorological data and land options that have not yet submitted a queue request due to a backlog of similar requests and inadequate transmission infrastructure. In spite of its wind potential, much of the wind resources in northwest Iowa and the surrounding region are yet to be developed and will likely remain in such a state; a lack of transmission infrastructure leaves the wind resources in this region electrically constrained from markets that have a large demand for clean, cost-effective, renewable energy. B. Market The Rock Island Clean Line will deliver energy into the PJM grid at the 765 kV Collins substation in Grundy County, Illinois. The PJM market is a competitive electric market with both merchant power sales and long-term contract possibilities. The Project serves a need for renewable -5- energy resources in the PJM footprint, whose renewable demand far outstrips its supply in the near future. As shown in Figure 4 and Tables 2 and 3 below, based on state-level renewable energy mandates there is huge demand for renewables in the delivery area and farther east. Figure 4: Renewable Energy Supply and Demand in PJM States Demand for renewable energy in PJM states ramps up significantly by 2016 and continues to climb through 2025. For the PJM states to reach their renewable energy procurement goals and mandates, they will need a dramatically increased ability to access cost-effective renewable energy resources. Rock Island will help meet RPS mandates and goals by delivering over 15,000 gigawatt- hours (“GWh”) of wind energy to PJM states each year, beginning in mid-2016. Renewable demand in PJM states and renewable demand for which Rock Island is eligible are shown in Tables 2 and 3, respectively. -6- Table 2: Total Renewable Demand—PJM States Renewables Wind Required at 40% RPS Mandate/Goal requirement (GWh) NCF (MW) PJM States 2016 2025 2016 2025 2016 2025 Delaware 14.50% 25.00% 1,739 3,193 496 911 Illinois 10.45% 22.71% 15,361 36,082 4,384 10,297 Indiana 3.22% 8.05% 3,478 9,268 992 2,645 Kentucky 0.00% 0.00% ‐ ‐ ‐ ‐ Maryland 15.20% 20.00% 10,134 14,202 2,892 4,053 Michigan 10.00% 10.00% 10,558 11,409 3,013 3,256 New Jersey 14.10% 22.50% 11,385 19,345 3,249 5,521 North Carolina 6.00% 12.50% 8,151 18,498 2,326 5,279 Ohio 3.97% 11.04% 6,326 18,731 1,805 5,345 Pennsylvania 13.80% 17.49% 21,131 28,529 6,031 8,142 Tennessee 0.00% 0.00% ‐ ‐ ‐ ‐ Virginia 6.02% 12.90% 6,949 16,221 1,983 4,629 West Virginia 9.94% 24.84% 3,273 8,723 934 2,489 DC 13.50% 20.00% 1,754 2,768 501 790 Total 100,239 186,969 28,607 53,359 Table 3: Rock Island Eligible Renewable Demand—PJM States Renewables Wind Required at 40% RPS Mandate/Goal requirement (GWh) NCF (MW) PJM States 2016 2025 2016 2025 2016 2025 Delaware 13.25% 21.50% 1,589 2,746 453 784 Illinois 9.82% 21.35% 14,439 33,917 4,121 9,680 Indiana 1.61% 4.02% 1,739 4,634 496 1,322 Kentucky 0.00% 0.00% ‐ ‐ ‐ ‐ Maryland 12.20% 18.00% 8,134 12,782 2,321 3,648 Michigan 0.00% 0.00% ‐ ‐ ‐ ‐ New Jersey 6.90% 14.52% 5,573 12,482 1,591 3,562 North Carolina 1.26% 2.87% 1,718 4,252 490 1,213 Ohio 1.91% 5.30% 3,036 8,991 867 2,566 Pennsylvania 5.55% 7.29% 8,492 11,887 2,424 3,392 Tennessee 0.00% 0.00% ‐ ‐ ‐ ‐ Virginia 6.02% 12.90% 6,949 16,221 1,983 4,629 West Virginia 9.94% 24.84% 3,273 8,723 934 2,489 DC 10.68% 17.50% 1,387 2,422 396 691 Total 56,330 119,057 16,076 33,978 C.